Davis Polk AML/CFT head Dan Stipano was quoted in MoneyLaundering.com discussing the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (FinCEN) guidance that encourages banks to more frequently share details of suspicious clients and transactions with other banks.

The article noted that FinCEN cited section 314(b) of the Patriot Act to urge banks to share this information with foreign banks and their own overseas affiliates.

However, Dan emphasized that section 314(b)’s safe harbor only applies to exchanges of details on suspected instances of money laundering or terrorist financing. “Sharing any other information is potentially outside the scope. For those banks that have chosen not to use section 314(b), the guidance provides no real incentive to do so,” he said.

“FinCEN’s Data-Sharing Initiative Faces Uphill Climb,” MoneyLaundering.com (October 2, 2025) (subscription required)

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